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PFAS restrictions in food packaging are becoming an important compliance issue for thermoforming manufacturers, food tray producers and packaging buyers selling products in the European Union.
The EU Packaging and Packaging Waste Regulation, commonly known as PPWR, introduces requirements that affect the entire packaging supply chain. These requirements are not limited to the thermoforming process itself. They may involve plastic sheets, additives, coatings, inks, adhesives, barrier layers, recycled materials and other components that form part of the finished food package.
For manufacturers of thermoformed food packaging, the practical question is not simply whether a tray is made from PP, PET or another plastic. The key questions are:
Does the complete packaging system meet the applicable PFAS limits?
Can the material supplier provide sufficient compliance documentation?
Has the finished package been tested using an appropriate method?
Can the thermoforming process maintain consistent product quality?
Does the packaging design support future recyclability and material recovery?
This guide explains what thermoforming manufacturers should know about EU PPWR PFAS requirements and how to prepare their materials, equipment and quality-control processes.
Table of Contents
The EU PPWR regulates packaging and packaging waste, not thermoforming machines directly.
PFAS restrictions apply to food-contact packaging placed on the EU market.
A tray made from PP or PET is not automatically compliant simply because the base polymer is widely recyclable.
PFAS may be associated with coatings, additives, inks, adhesives, processing aids, recycled feedstock or other packaging components.
A machine supplier cannot guarantee PPWR compliance without reviewing the material, product design, tooling and production conditions.
Thermoforming manufacturers should request supplier declarations, technical data and suitable test reports before commercial production.
Equipment should provide stable heating, forming, cooling, trimming and stacking performance so that material and product specifications remain consistent.
PFAS-free packaging is only one part of wider PPWR preparation. Recyclability, recycled content, packaging minimization and documentation also require attention.
PFAS means per- and polyfluoroalkyl substances. This is a large group of fluorinated chemicals that have been used in different industrial and consumer applications because of their resistance to grease, oil, water, heat and chemical degradation.
In food packaging, PFAS have historically been associated with applications that require grease or moisture resistance. They may be used in certain coatings, treatments, additives or processing systems. However, PFAS may also be present unintentionally through raw materials, recycled feedstock, contaminated production equipment or materials used elsewhere in the packaging structure.
For thermoforming manufacturers, PFAS should be considered as part of the entire packaging material system. The thermoformed tray itself may be only one component. A complete food package may also include:
A plastic tray or container
A lidding film
A coating or barrier layer
Printing inks
Adhesives
Labels
Absorbent pads
Sealants
Processing aids
Recycled or reprocessed material
A supplier declaration for the main plastic sheet is useful, but it may not be sufficient to demonstrate compliance for the finished package. Each component and the complete structure should be evaluated according to the intended food-contact application and destination market.
The Packaging and Packaging Waste Regulation introduces requirements concerning substances of concern in packaging. One important measure concerns PFAS in food-contact packaging.
The regulation establishes concentration limits for PFAS in food-contact packaging. Packaging that exceeds the applicable limits cannot be placed on the EU market after the relevant application date. The requirements cover different PFAS measurement categories, which means that a single general statement such as “fluorine-free” may not provide enough technical evidence by itself.
Manufacturers and importers should therefore avoid treating PFAS documentation as a simple marketing certificate. Compliance normally requires a combination of:
Material information
The packaging producer should understand the composition of the plastic sheet, additives, coatings and other components.
Supplier declarations
Raw-material suppliers should provide current declarations covering the intended application and relevant regulatory requirements.
Analytical testing
Testing should be performed by a competent laboratory using an appropriate analytical approach.
Production traceability
Batch numbers, material sources, production records and test reports should be linked to the final packaging product.
Change control
A change in resin grade, sheet supplier, coating, ink, adhesive or recycled content may require a new compliance review.
The PPWR does not mean that a thermoforming machine is required to carry a special “PFAS-free machine” certification. The machine is a production tool. The compliance status belongs to the packaging product and its material system.
Manufacturers should consult the official EU regulation and current implementation guidance before making a final compliance decision. National market-surveillance authorities and customers may also request supporting documentation.
Thermoforming is widely used to produce food trays, takeaway containers, produce trays, meat trays, bakery containers and ready-meal packaging. The process heats a plastic sheet and forms it over a mold using vacuum, pressure or a combination of both.
The process itself does not automatically add PFAS to the packaging. However, manufacturers must control the full production chain because the finished product is evaluated as packaging placed on the market.
PFAS requirements are important for thermoformed packaging for several reasons.
Food packaging is not only evaluated for appearance and mechanical strength. Customers may also request evidence relating to food-contact safety, migration, substances of concern and material composition.
A thermoforming manufacturer serving European customers should be prepared to provide more than a product catalogue. Buyers may ask for:
Material composition
Food-contact declarations
PFAS statements
Test reports
Migration information
Batch traceability
Information about recycled content
Details of coatings, inks and adhesives
PFAS reduction or elimination may require changes to the material structure, coating system or barrier solution. These changes can influence:
Sheet stiffness
Heating behavior
Forming temperature
Stretch ratio
Wall-thickness distribution
Sealing performance
Surface appearance
Trimming quality
Stacking performance
For this reason, a material change should be validated on the actual thermoforming line rather than approved only on paper.
PPWR preparation is broader than removing one chemical group. Food packaging may also need to support recycling, contain required levels of recycled content where applicable and avoid unnecessary material combinations.
A tray may be technically PFAS-compliant but difficult to recycle because it contains incompatible polymers, excessive coatings, complex labels or non-compatible attachments. Packaging designers should evaluate the complete structure instead of focusing on one requirement in isolation.
PFAS can potentially be associated with more parts of a packaging system than the thermoformed sheet alone. A risk review should include the following areas.
The starting sheet may contain additives or processing aids supplied by the resin producer or sheet manufacturer. A general declaration for the polymer type does not necessarily describe every additive used in the sheet.
Manufacturers should request information specific to the sheet grade and intended food-contact use.
Some food products require additional protection against grease, oxygen, moisture or aroma transfer. Coatings and barrier layers may affect the chemical profile and recyclability of the finished package.
Any coating used on the sheet or finished tray should be included in the compliance review.
A printed label or adhesive can become part of the packaging system even when it is not directly applied to the food-contact surface. Depending on the package design, migration, contamination and recycling considerations may still be relevant.
The packaging producer should coordinate with ink, label and adhesive suppliers instead of treating the tray material separately.
Recycled material can support circular-economy goals, but its quality and composition must be controlled. The recycled feedstock should have a known source, controlled processing history and suitable documentation.
Manufacturers should not assume that recycled content is automatically PFAS-free or automatically suitable for direct food contact.
Cross-contamination may occur when the same production area handles different coatings, additives or materials. Good housekeeping, material segregation, line-cleaning procedures and traceability can help reduce this risk.
The precise control measures will depend on the factory, product range and quality-management system.
The base polymer is an important part of food packaging design, but polymer selection alone does not determine PFAS compliance.
Polypropylene is commonly used for food trays and containers because it offers good chemical resistance, heat resistance and processability. PP may be suitable for microwaveable containers, ready meals, takeaway packaging and other applications, depending on the product requirements.
However, a PP food tray still requires a review of:
Resin grade
Additives
Sheet production process
Recycled content
Coatings
Printing
Sealing materials
Intended temperature and food-contact conditions
PET is commonly selected for applications requiring transparency, stiffness and a strong visual presentation. It can be used for bakery products, fresh produce, prepared foods and other packaged products.
For PET packaging, manufacturers should evaluate the complete sheet structure, including recycled PET content, barrier layers, coatings and lidding compatibility.
PS and other plastic materials may still be used in selected food packaging applications, but market acceptance, recycling infrastructure, customer requirements and regional regulations should be considered carefully.
The correct material depends on the product, shelf-life target, temperature, sealing method, mechanical requirements and end-of-life system. There is no single polymer that is automatically the best option for every food tray.
Before selecting a thermoforming machine or sheet material, define:
Food type
Contact temperature
Heating or freezing conditions
Required shelf life
Tray dimensions
Forming depth
Wall-thickness target
Sealing method
Transparency or color requirements
Recycled content target
Destination market
Required documentation
This information creates a more reliable basis for selecting a material and machine configuration.
Create a material map for each food packaging product. Record the composition and supplier of every major component, including the tray, lid, coating, label, adhesive and pad.
This helps identify information gaps before a customer or regulator requests documentation.
Supplier declarations should be product-specific and up to date. Avoid relying on a generic statement that only identifies the material as “PP,” “PET” or “food grade.”
Ask suppliers whether the declaration covers:
PFAS
Food-contact use
Applicable EU requirements
Additives and processing aids
Recycled content
Intended temperature conditions
Product-batch traceability
Testing should be based on the packaging structure and the intended market. Depending on the product, a testing plan may include:
PFAS analysis
Total fluorine screening
Targeted PFAS analysis
Overall migration testing
Specific migration testing
Mechanical testing
Seal-strength testing
Recyclability or material-identification testing
Testing should be arranged with a qualified laboratory. A screening test may identify a potential issue, but it may not replace the analytical method required for regulatory documentation.
A new sheet supplier, resin grade, coating or adhesive can change the compliance profile and production performance. Implement a change-control procedure that requires technical review before a new material enters mass production.
Material trials should use the actual machine, mold and production conditions whenever possible. The trial should review:
Heating profile
Forming pressure
Vacuum level
Plug-assist settings
Cooling time
Cycle time
Wall-thickness distribution
Dimensional accuracy
Trimming quality
Stacking stability
Surface appearance
A material that performs well in a laboratory may require different processing parameters on a commercial production line.
When purchasing a thermoforming machine for food packaging, buyers should discuss both production requirements and material-validation requirements.
The heating system should provide stable and controllable temperatures across the sheet. Uneven heating can cause inconsistent thickness, incomplete forming and dimensional variation.
Ask the supplier about:
Heating zones
Temperature-control accuracy
Heating element configuration
Sheet tracking
Heating recipes for different materials
Energy-management functions
Pressure forming may improve detail reproduction and help form packaging with more complex geometry. Vacuum forming may be suitable for simpler shapes and different production requirements.
The appropriate process depends on the tray design, material and required surface detail. MINGDU offers both pressure forming machines and pressure and vacuum forming machines for different thermoforming applications.
Mold design affects wall-thickness distribution, forming depth, cycle time and product quality. Cooling performance is especially important in high-speed food tray production.
Discuss:
Mold material
Cooling-channel design
Forming depth
Draft angles
Part release
Cutting position
Stacking orientation
Expected cycle time
A food tray line should be evaluated as a complete production system. Accurate cutting and stable stacking can reduce rejects and improve downstream packing efficiency.
Ask how the equipment handles:
In-line cutting
Scrap removal
Edge quality
Automatic stacking
Product counting
Product transfer
Compatibility with downstream packaging equipment
If the project involves recycled content, a new sheet structure or PFAS-related material changes, ask whether the supplier can support a material trial using the intended product design.
A machine supplier should clearly state what can be validated by the equipment trial and what must be confirmed by a laboratory or regulatory specialist.
MINGDU manufactures thermoforming equipment for plastic food trays, containers, lids and related packaging applications. Depending on the product design and production requirements, customers may evaluate different machine configurations.
For standard tray and container applications, the plastic food tray container thermoforming machine can be reviewed according to the required tray dimensions, sheet material and output target.
For customers working with different sheet materials or customized packaging structures, the customizable pressure sheet thermoforming machine for food packaging may be considered after reviewing the product drawings and forming requirements.
For projects involving BOPS, PP or PET materials, buyers can also review the BOPS, PP and PET thermoforming machine and confirm material compatibility through a technical discussion and production trial.
MINGDU equipment can support the forming, cutting and stacking stages of food packaging production. However, machine selection alone does not establish PPWR compliance. The final packaging producer remains responsible for confirming the materials, testing, documentation and market-access requirements for the finished product.
Use the following checklist when preparing thermoformed food packaging for EU customers.
The complete packaging structure has been mapped.
The plastic sheet grade and supplier are recorded.
Additives and processing aids have been reviewed.
Coatings and barrier layers have been identified.
Inks, labels and adhesives have been included in the assessment.
Recycled content and its source have been documented.
The intended food-contact application has been defined.
Current supplier declarations are available.
PFAS information is product-specific.
Food-contact declarations cover the intended conditions of use.
Material batch numbers can be traced.
Suppliers have a process for notifying material changes.
A suitable PFAS testing strategy has been established.
The laboratory method matches the regulatory and customer requirements.
Migration testing has been reviewed where necessary.
Production samples are traceable to material batches.
Material changes trigger a technical review.
Production trials have confirmed forming and trimming stability.
Heating zones are suitable for the selected sheet.
Vacuum or pressure settings can be controlled consistently.
Mold cooling is adequate for the target cycle time.
Cutting and stacking performance meets the product specification.
Scrap and reject rates are monitored.
The machine supplier has clearly defined the scope of its support.
No. The PPWR establishes specific requirements and concentration limits for PFAS in food-contact packaging. Manufacturers should evaluate the applicable limit categories and testing requirements instead of describing the regulation as a simple blanket ban on every fluorinated substance.
No. PP and PET identify the base polymer, but they do not describe every additive, coating, adhesive, ink or recycled material used in the finished package. The complete packaging structure must be reviewed.
A thermoforming machine can process suitable materials into food trays, but it does not determine whether the material system is PFAS-compliant. Compliance depends on the materials, components, testing and documentation associated with the finished packaging.
Recycled plastic should be evaluated according to its source, processing history, supplier documentation and intended food-contact use. Recycled content can support circular packaging goals, but it should not be assumed to be PFAS-free without appropriate evidence.
At minimum, request a current material specification, food-contact declaration, PFAS statement, recycled-content information where applicable, batch traceability and notification procedures for material changes. Additional test reports may be required by the customer or destination market.
No. PFAS is only one part of PPWR preparation. Packaging may also need to meet requirements related to recyclability, recycled content, minimization, labeling, reuse or other substances of concern.
Provide the tray drawings, length, width, height, forming depth, material, sheet thickness, mold layout, target output, cutting method, stacking requirements and intended market. If recycled or modified materials are planned, include the relevant material data and request a production trial.
MINGDU can discuss thermoforming equipment, material processing and production requirements. Final regulatory compliance should be confirmed by the packaging producer together with material suppliers, testing laboratories and qualified regulatory professionals.
PFAS restrictions in food packaging create a stronger need for material transparency, testing and production traceability. For thermoforming manufacturers, the most effective approach is to evaluate the complete packaging system instead of focusing only on the plastic tray or the thermoforming machine.
Start by mapping every material component, requesting current supplier documentation and identifying the appropriate testing strategy. Then validate the selected sheet, mold and production parameters on the intended thermoforming line.
A stable machine process can help manufacturers maintain consistent dimensions, wall thickness, trimming quality and production efficiency. However, PPWR compliance depends on the finished packaging product, its material structure and the supporting evidence.
If you are developing a PP, PET or other thermoformed food packaging project, contact MINGDU with your tray dimensions, material, sheet thickness and target output. Our team can help you review a suitable thermoforming machine configuration for your production requirements.
Tell us your tray dimensions, material and target output to receive a machine recommendation.
This article provides general technical and business information and does not constitute legal advice. PPWR requirements, implementation guidance and national enforcement practices may be updated. Always confirm the latest official EU requirements before placing food-contact packaging on the European market.
